16 Contaminated Land - Ken Read

Before Hearing Commissioners
under:
in the matter of:
the Resource Management Act 1991
notices of requirement and resource consent
applications by the NZ Transport Agency and Hamilton
City Council for the Southern Links Project
Statement of evidence of Ken Read (Contaminated Land) on behalf of the
NZ Transport Agency and Hamilton City Council
Hearing date:
21 July 2014
Dated:
12 June 2014
REFERENCE:
Suzanne Janissen ([email protected])
Jo Bain ([email protected])
Chapman Tripp
T: +64 9 357 9000
F: +64 9 357 9099
23 Albert Street
PO Box 2206, Auckland 1140
New Zealand
www.chapmantripp.com
Auckland, Wellington,
Christchurch
Tompkins Wake
T: +64 7 839 4771
F: +64 7 839 4855
Westpac House
430 Victoria Street
PO Box 258, DX GP20031
Hamilton 3240
New Zealand
www.tomwake.com
STATEMENT OF EVIDENCE OF KEN READ ON BEHALF OF THE
NZ TRANSPORT AGENCY AND HAMILTON CITY COUNCIL
INTRODUCTION
1 SCOPE OF EVIDENCE
2 SUMMARY OF EVIDENCE
2 MY ROLE IN THE PROJECT
3 EXISTING ENVIRONMENT
4 CONTAMINATED LAND ASSESSMENT CRITERIA
5 ASSESSMENT OF CONTAMINATED LAND EFFECTS
7 MITIGATION OF CONTAMINATED LAND EFFECTS
8 COMMENTS ON SUBMISSIONS
9 COMMENTS ON S42A REPORT AND RECOMMENDED CONDITIONS
9 CONCLUSIONS
11 Annexure A - Table 1: Potentially Contaminated Properties affected
by the Project
12 Annexure B – Figure 6: Location of potentially contaminated
properties
13 100059484/3424455
1
STATEMENT OF EVIDENCE OF KEN READ ON BEHALF OF THE
NZ TRANSPORT AGENCY AND HAMILTON CITY COUNCIL
INTRODUCTION
1
My full name is Kenneth John Read.
2
I hold a Bachelor of Science (Honours) in Geology from Edinburgh
University, graduating in 1982, and a Masters of Science in
Engineering Geology from Newcastle University, graduating in 1984.
3
I have been a Chartered Professional Engineer (CPEng) since 2009,
and I am a member of IPENZ. I am also a Chartered Geologist
(CGeol (UK)) since 1994 and a Fellow of the Geological Society.
4
Since 1984, I have predominantly worked in engineering
consultancies providing site investigation, geotechnical and
engineering geological advice and design services for many civil
engineering and development related works. This has included
domestic, retail and industrial developments, highways, dams,
water and waste water treatment works and bridges. Since 1988,
many of my projects have involved development on potentially
contaminated sites in the United Kingdom and New Zealand.
5
From 1992 to 1995, I worked for a UK site investigation contractor
as its Principal Geotechnical Engineer. The role involved planning,
managing and reporting on site investigations for structures,
motorways, tunnels and housing developments. Between 1995 and
2006, I worked in several consultancies variously as a Principal and
Senior Engineering Geologist/Geotechnical Engineer. Projects
comprised domestic housing developments, prisons, highways, sea
outfalls, landfills and industrial developments.
6
I moved to New Zealand in 2006, taking up the position of Senior
Engineering Geologist with Opus International Consultants in
Hamilton. I was made Geotechnical Group Manager in Hamilton in
2011. In that role, I have been responsible for assessment of
contaminated land effects of the Tamahere-Cambridge and the
Hamilton Sections of the Waikato Expressway.
7
I have recently presented geotechnical evidence in support of the
Ruakura Development Plan Change to a Board of Inquiry on behalf
of Tainui Group Holdings.
8
My evidence is given in support of notices of requirement (NORs)
and applications for resource consents lodged by the NZ Transport
Agency (the Transport Agency) and Hamilton City Council (HCC) on
9 August 2013 in relation to the construction, operation and
maintenance of the Southern Links Project (Project).
100059484/3424455
2
9
I am familiar with the area that the Project covers, and the existing
State highway and the local roading network in the vicinity of the
Project.
10
I have prepared the Preliminary Contaminated Land Report
(Contaminated Land Report) which is provided as Appendix R to the
Assessment of Environmental Effects (AEE) lodged in support of the
NORs.
11
I confirm that I have read the ‘Code of Conduct for Expert
Witnesses’ contained in the Environment Court Practice Note 2011.
To the extent that the Code is relevant to my statement of
evidence, my evidence has been prepared in compliance with that
Code in the same way as I would if giving evidence in the
Environment Court. In particular, unless I state otherwise, this
evidence is within my sphere of expertise and I have not omitted to
consider material facts known to me that might alter or detract from
the opinions I express.
SCOPE OF EVIDENCE
12
My evidence will deal with the following:
12.1
Summary of evidence;
12.2
My role in the Project;
12.3
Existing environment;
12.4
Contaminated land assessment criteria;
12.5
Assessment of contaminated land effects;
12.6
Mitigation of contaminated land effects;
12.7
Comments on submissions;
12.8
Comments on s42A Report and recommended conditions; and
12.9
Conclusions.
SUMMARY OF EVIDENCE
13
The work I have carried out to date has identified a number of
properties within the designation footprint that have, or have had, a
use or uses that could potentially lead to soil contamination.
14
Although those properties have been identified as “potentially
contaminated”, the activity that has led to that classification may
not have caused contamination or may not have been within the
100059484/3424455
3
area of the property within the designation footprint. While further
investigation is needed and will be undertaken at the detailed design
stage of the Project, if any contamination is present at those sites,
in my experience, in many cases it is likely to be limited to small
localised areas.
15
I am not aware of any work undertaken to date to confirm the
presence of contaminated soils on the areas of these properties
affected by the designation.
16
The rural nature of much of the area under consideration means
that the majority of potential contaminants arise from the use of
agrichemicals (residual pesticides and herbicides) and farm waste
disposal (offal pits and farm tips).
17
Some commercially derived contamination is possible at the
northern end of State Highway 3 (SH3), and industrial derived
contamination may be present at the junction of the east west link
with the existing State Highway 1 intersection of Kahikatea Drive
and Greenwood Street.
18
It is unlikely that all potentially contaminated properties within the
proposed designation have been identified to date. This is because
my work to date is a largely desk-based study of records that may
not be complete. Further, the majority of agricultural/rural
contamination arises from activities that are themselves unrecorded
(e.g. farm tip/offal pits), or the locations of which are unrecorded
(e.g. sheep dips and spray mixing).
19
I consider that provided further investigation and assessment of
potentially contaminated properties is made at the detailed design
stage, and that it is undertaken in accordance with the relevant
legislation and guidance that applies at the time, the potential
hazards posed by soil contamination to the environment and human
health arising from the Project can be appropriately mitigated and
managed.
20
I have reviewed the s42A Report and, subject to minor
amendments, support the inclusion of a Contaminated Soil
Management Plan (CSMP). I consider that any contaminated land
effects will be adequately avoided, remedied or mitigated through
the implementation of the CSMP.
MY ROLE IN THE PROJECT
21
I have been involved in the Project since November 2010. My role
was initially to carry out a preliminary appraisal of potentially
contaminated land present within the Southern Links Study Area.
100059484/3424455
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22
In February 2011, I reported this work in my report entitled
“Southern Links, Contaminated Land Assessment Preliminary
Appraisal Report”).1 For this work, I obtained historic and present
land use data from Waikato Regional Council (Waikato RC),
Hamilton City Council (HCC), and Waipa and Waikato District
Councils (Waipa DC and Waikato DC). I also participated in an area
wide site visit to familiarise myself with the area and to look from
the road side for unrecorded potentially contaminative activities
such as farm tips.
23
In April 2012, I prepared a report entitled “Southern Links, Scheme
Assessment, Preliminary Contaminated Land Assessment”.2 In this
report, I assessed the possibility of potentially contaminated sites
being present within the better defined route corridors known as the
‘Preferred Network’ being considered at that time. This report was
based on data obtained for my previous report.
24
In mid 2013, I was then instructed by the Transport Agency and
HCC to prepare the Contaminated Land Report for the Project,
lodged as part of the AEE as Appendix R.3
25
I have not carried out any further work with respect to
contaminated land in the Project area since lodgement of the NORs
in August 2013, nor do I consider it necessary to do so for the
purposes of preparing my evidence.
EXISTING ENVIRONMENT
26
Much of the Project area is rural. While the rural land is mainly
pasture, some food crops are grown. Isolated farm houses and
pockets of residential development are present, with some operative
and now closed orchards. In these areas, potential contaminative
activities are primarily associated with the use of pesticides and
herbicides. There are also possible sheep dips, offal pits and farm
tips, the locations of which are seldom recorded.
27
Industrial or commercial land uses within the Project area are
concentrated at the northern end of the proposed State Highway 1
(SH1) extension at Kahikatea Drive and at the southern end of the
SH3 realignment close to the Hamilton Airport. In these cases, the
nature of any potential contamination is closely linked to each
particular industrial or commercial activity.
1
“Southern Links, Contaminated Land Assessment Preliminary Appraisal Report”
(ref G2896, Issue 1, dated February 2011).
2
“Southern Links, Scheme Assessment, Preliminary Contaminated Land
Assessment” (G3012, Issue 1, dated April 2012).
3
“Southern Links, Notice of Requirement, Preliminary Contaminated Land
Assessment” (G3145, Issue 1, dated August 2013).
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28
The dominant surface water features in the study area is the
Waikato River and associated tributaries. The Waikato River flows
south-east or north-west along the eastern margin of the Project
area, with tributaries in generally shallow valleys tending primarily
south-west to north-east across much of the Project area. These
valleys develop into major incised gullies towards the Waikato River.
29
There are a small number of minor ponds and lakes associated with
some of the tributary streams.
30
In the west of the area, the much more flat lying Rukuhia Swamp is
criss-crossed by a series of drains.
31
Waikato Regional Council list eleven consented surface abstraction
points within the Project area; six of which are from the Waikato
River, the remainder are thought to be from ponds in the central
part of the study area.4 I have assumed these abstraction points to
be for domestic and agricultural supply.
32
Groundwater is very shallow in the west of the Project area over the
Rukuhia Swamp. To the east of the Project area, groundwater level
is thought to be controlled by the Waikato River, and local variation
in the underlying geology, with perched water levels possible in the
mixed soil horizons present.
33
Groundwater flow is expected to be predominantly towards the
Waikato River with some local influences possibly towards the small
lakes and ponds seen in some areas. I would expect flow rates to
be highly variable in the various soil types across the study area.
34
Waikato RC lists fifteen consented groundwater abstraction points.4
It is likely however that a number of rural properties in the area
may have shallow water bores that are unrecorded. These bores
are expected to be for domestic and agricultural use.
CONTAMINATED LAND ASSESSMENT CRITERIA
35
The identification, assessment and management of contaminated
land in New Zealand is managed under:
4
35.1
The “Resource Management (National Environmental
Standard for Assessing and Managing Contaminants in Soil to
Protect Human Health) Regulations 2011” (NES); and
35.2
Contaminated Land Management Guidelines No.1, Reporting
on Contaminated Sites in New Zealand, Ministry for the
Environment, 2003 (MfE Guidelines).
Waikato Regional Council web site: Maps - This is a GIS interactive map facility
which was searched for consented ground and surface water abstractions.
100059484/3424455
6
36
On a local level the management of contaminated land is governed
by the Waikato Regional Plan, Section 5.3 “Contaminated Land” and
Section 4 of the Proposed Hamilton City District Plan “Development
Suitability”. The Hamilton City District Plan focuses on effects on
human health and the Regional Plan focuses on effects on the
natural environment.
37
Section 9 of the Waikato District Council Plan and Section 19 of the
Proposed Waipa District Plan both seek to manage environmental
and human health risks associated with contaminated land and
associated remedial works. All of my earlier reports referred to the
MfE Guidelines, and my Contaminated Land Report acknowledged
the introduction of the NES, which was enacted in January 2012,
after my earlier reports were prepared.5
38
My Contaminated Land Report is essentially a ‘Preliminary Site
Inspection’ report, as defined in the MfE guidance and the NES,
which identifies potentially contaminated sites.
39
The Ministry of the Environment has prepared the Hazardous
Activities and Industries List (HAIL) which is widely used to identify
properties that may have hosted potentially contaminative activities.
Waikato RC is working with HCC and Waipa DC and Waikato DC to
compile a register of properties within the Region where HAIL
activities have historically or are currently being carried out. This
register is known as a ‘Selected Land Use’ list. Regional Councils
also hold records of any works being carried out to remediate
contaminated sites. The Selected Land Use Registers (SLURs) were
the primary source of potentially contaminated site identification
used in my Contaminated Land Report.6
40
As described in my Contaminated Land Report,7 the SLURs held by
Waikato RC, Waikato DC and Waipa DC and HCC are a work in
progress and may not be complete. Further, they identify entire
properties as potentially contaminated, whereas the activity that has
caused this listing may only have been restricted to a small or
isolated area within that property.
41
I identified a number of sites as potentially contaminated based on a
previous or existing HAIL land use. At this time, I have not been
instructed to undertake any further work to confirm the presence of
contaminated soils on these sites or any other sites affected by the
NORs, nor do I consider it necessary to do so at this stage.
5
Contaminated Land Report, pages 1 and 2.
6
Contaminated Land Report, page 6. The SLURs contain information about
confirmed contaminated sites and potentially contaminated sites (using the HAIL
classification).
7
Contaminated Land Report, page 6.
100059484/3424455
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42
Under the NES and MfE Guidelines, a staged approach should be
adopted for further investigation and assessment of sites identified
as potentially contaminated. This comprises preparation of:
43
42.1
A Detailed Site Investigation and Report (DSI, possibly
multi-phased);
42.2
A Remediation Action Plan (RAP);
42.3
A site verification report (SVR) describing and recording the
remedial works carried out and the condition of the site on
completion of these; and
42.4
A Monitoring and Management Plan, if future monitoring of
the remediated site is required.
At the design stage, resource consents for associated earthworks
and possible disposal of contaminated soils may be needed in
compliance with the NES, the Regional Plan and the District Plans.
ASSESSMENT OF CONTAMINATED LAND EFFECTS
44
Undertaking earthworks on contaminated land can expose site
workers, people on neighbouring properties, surface water courses
and groundwater to potentially harmful contaminants, if such
contaminants are released and are present in concentrations above
the thresholds identified in the NES.
45
Typically, the pathways for harm to people are via skin contact,
inhalation and ingestion. In most cases, the risks of this potential
harm being realised can be managed by conventional good
engineering practice, by good hygiene and safety practice during
construction breaking these pathways.8
46
The release of any contaminants to surface water can be controlled
by best practice erosion and sediment control measures.9
47
Release of contaminants to groundwater however needs to be
assessed on a case by case basis, looking at the individual site
geology and the nature of the contamination. I have identified in
my Contaminated Land Report that groundwater is a high risk
receptor of potential contamination throughout the area.10
8
Contaminated Land Report, pages 7 and 8 - ref. G3145.
9
Such practices will form part of the applications for resource consents for the
Project, and required by consent conditions. The resource consent applications
will be prepared following detailed design.
10
Contaminated Land Report, pages 8.
100059484/3424455
8
48
In Annexure A to my evidence, I provide a list of those sites
identified from the records obtained as potentially contaminated,
together with the HAIL activity, and a qualitative description of
where the maximum risk of encountering contamination lies. The
locations of these sites are shown in Figure 6 of the Contaminated
Land Report, a copy of which is appended to my evidence as
Annexure B.11
49
Following good practice and in compliance with current legislation, I
consider that further investigation of these sites will be necessary to
confirm or otherwise the presence and nature of any contamination
(via a DSI). If contaminated soils are present, an RAP will be
needed, followed by preparation of a SVR. I recommend that the
requirements for these steps be incorporated into the CSMP.
MITIGATION OF CONTAMINATED LAND EFFECTS
50
Provided the following recommendations made in Section 6 of my
Contaminated Land Report12 are followed during latter stages of the
Project, I consider that the potential risks posed by contaminated
soils can be suitably managed:
50.1
All works associated with the investigation, assessment and
remediation of contaminated land must be overseen and
controlled by a Suitably Qualified and Experienced Practitioner
(SQEP) as required by the NES.
50.2
That assessment should comprise the following staged
approach – detailed assessment of the documented history of
the property, field investigation of the property, assessment
of consequential effects on the network design and
construction methodologies, risk assessment of the site and
potential risks to human health and the environment posed
by any contamination found must be assessed.13
51
At the detailed design and resource consent stage, it is my
experience that suitable resource consent conditions can be included
to ensure compliance with MfE guidance, the NES and relevant
Regional and District Plan provisions.
52
As discussed below, I support the inclusion of a CSMP as proposed
by the s42A authors.
11
Note that Figure 6 (Revision 1) is appended because it now includes the Hamilton
Gardens site that was mistakenly excluded earlier.
12
Contaminated Land Report, pages 7 to 10.
13
I provide more detail regarding the risk assessment on page 9 of my
Contaminated Land Report.
100059484/3424455
9
COMMENTS ON SUBMISSIONS
53
I have read submissions lodged on the Project. I have not identified
any that specifically raise contaminated land effects.
54
I consider that provided the recommendations explained above are
followed, any actual contamination that may be present on
properties affected by the Project will be identified and managed
appropriately, as required by the NES and the updated designation
conditions.
COMMENTS ON S42A REPORT AND RECOMMENDED
CONDITIONS
55
I have read the s42A Report prepared on behalf of HCC, Waipa and
Waikato District Councils dated 30 May 2014 (s42A Report) and the
Technical Specialist Report prepared by Dr Paul Heveldt (Appendix J
to the s42A Report) (Specialist Report). I have no contrary
comments to make on the contents of the s42A Report.
56
I note that Dr Heveldt considers my Contaminated Land Report is of
sufficient coverage and detail to give confidence that contaminated
land will be satisfactorily quantified at the time of construction and
mitigated through the proposed conditions.14
57
The s42A authors note that Dr Heveldt considers the investigations
undertaken to date to be appropriate, and that he agrees with the
recommendations in my Contaminated Land Report.15
58
The s42A report notes that my assessment may not have taken into
consideration potentially contaminated sites within Hamilton City.16
To clarify, my assessment did include the identification of potentially
contaminated land within Hamilton City. While, several sites were
identified, the majority of these sites are not within or in proximity
to the proposed designation boundaries. However, I accept that one
site, the Hamilton Gardens, is crossed by the proposed designation
but, in error, was not included as a highlighted property at Figure 6
or detailed in the body of the Contaminated Land Report. This has
been corrected in Annexure B to this evidence.
59
At the detailed design stage, Hamilton Gardens and all other
properties within the NOR in Hamilton City will need to be assessed
in detail as per all other areas within the NOR.
60
Subject to some minor amendments, I support the conclusions and
proposed conditions discussed in Section 5 of the Specialist Report
14
Specialist Report, sections 4.1 and 5.
15
Section 42A Report, at section 16.5.
16
Section 42A Report, at section 16.5.
100059484/3424455
10
carried through into the s42A Report.17 In particular, I agree with
the recommendation for a specific condition requiring the
preparation and implementation of a CSMP.
61
I propose the following amendments be made to the CSMP
conditions recommended in the s42A Report:18
Contaminated Soil Management Plan
23.1
Prior to the commencement of construction, the Requiring
Authority shall engage a Suitably Qualified and Experienced
Practitioner to prepare a Contaminated Soil Management Plan
(CSMP). The Requiring Authority shall adhere to the relevant
requirements of the CSMP at all appropriate times during the
Project. The purpose of the CSMP shall be to avoid, remedy or
mitigate the adverse effects of any enabling works and the
construction of the Project on human health and the
environment which may result from the disturbance of
contaminated soil/material.
23.2
The CSMP shall be provided to the Chief Executive Officer or
nominee of the Territorial Authority for certification at least 40
working days prior to construction activities being undertaken.
23.3
As a minimum the CSMP shall include the following details:
a)
Details of any investigation, assessment, reporting and
management of contaminated land or potentially
contaminated land that has carried out;
b)
The measures to be undertaken in the handling, storage
and disposal of all contaminated material excavated
during the construction works;
c)
The soil validation testing that will be undertaken;
d)
The soil verification testing that will be undertaken to
determine the nature of any contamination in excavated
spoil and the potential reuse or disposal options for that
spoil;
e)
How the placement of any re-used contaminated soil /
material will be recorded and tracked;
f)
Measures to be undertaken in the event of unexpected
contamination being identified during construction
activities, including measures to:
g)
h)
i.
Assist with identification of unknown contaminated
material;
ii.
Stop work or isolate the area once any such
material is identified;
The measures to be undertaken to:
i.
Protect the health and safety of workers and the
public;
ii.
Control stormwater runon and runoff;
iii.
Remove or manage any contaminated soil;
iv.
Remediate any required sites.
The measures to be undertaken to:
17
Section 42A Report, Appendix J.
18
Section 42A Report, Appendix A.
100059484/3424455
11
i.
Identify any suspected asbestos;
ii.
Identify the type of asbestos and confirm the
appropriate means by which it shall be removed;
iii.
Handle any asbestos containing material.
23.4
A Suitably Qualified and Experienced Practitioner shall supervise
the implementation of Tthe measures required in condition 20.3
above. shall also include appointment of a Suitably Qualified and
Experienced Practitioner to implement the actions identified in
the CSMP.
23.5
At the completion of the construction of the Project, a validation
report will be prepared by a Suitably Qualified and Experienced
Practitioner in accordance with any Ministry for the Environment
guidelines and the National Environmental Standard for
Assessing and Managing Contaminants in Soil to Protect Human
Health and submitted to the Chief Executive Officer or nominee
of the Territorial Authority documenting the management of
contaminated soil and evidence of appropriate disposal. The
validation report shall include a record of all analytical results,
volumes, tip receipts, and any incidents or complaints and how
these were addressed. The validation report shall also identify
any areas which need on-going monitoring and management by
the Requiring Authority.
62
I particularly support the inclusion of the specific reference to
asbestos in the s42A author’s proposed conditions as in my
experience asbestos containing materials are a common occurrence
in farm tips (recommended condition 20.3(h)).
63
My proposed updated conditions are incorporated in the planning
evidence of Mr Eccles.
CONCLUSIONS
64
I consider on the basis of works carried out to date, and provided
the proposed methods of future identification, investigation and
management of potentially contaminated land within the designation
footprint are adopted and followed, construction of the Project can
be carried out in a manner that adequately protects human health
and the environment from possible adverse effects associated with
contaminated soil.
65
I consider that the proposed conditions are adequate to protect
human health and the environment from potential adverse effects
caused by disturbance of contaminated soils.
Kenneth Read
12 June 2014
Annexures
A
Potentially Contaminated Properties affected by the Project
B
Location of potentially contaminated properties.
100059484/3424455
12
ANNEXURE A - TABLE 1: POTENTIALLY CONTAMINATED
PROPERTIES AFFECTED BY THE PROJECT
SITE ID19 SITE NAME
HAIL
ACTIVITY(IES)
8818
Sunfruit
Orchards
Ltd
A10, A17
Persistent pesticide bulk
Greatest risk is at storage
storage or use including
and mixing/preparation
sport turfs, market gardens, areas of pesticides.
orchards, glass houses or
spray sheds
9760
Narrows
Golf Club
A17
Storage tanks or drums for
fuel, chemicals or liquid
waste
11272
TJL Heritage A10
Persistent pesticide bulk
Greatest risk is at storage
storage or use including
and mixing/preparation
sport turfs, market gardens, areas of pesticides.
orchards, glass houses or
spray sheds
11326
Titoki Sands A10
Limited
Persistent pesticide bulk
Greatest risk is at storage
storage or use including
and mixing/preparation
sport turfs, market gardens, areas of pesticides.
orchards, glass houses or
spray sheds
15305
D&T
McDonalds
Limited
G3, G4
Landfill sites, Scrap yards
including automotive
dismantling, wrecking or
scrap metal yards
Margin of the property
affected by the proposed
designation.
27589
Hamilton
Organic
Recycling
Centre
G6
Hydrocarbon exploration or
production including well
sites or flare pits
Likely to be localised in
storage areas. About 25%
of the property affected by
the proposed designation.
79545
Animal
I
Breeding
Services Ltd
Any other land that has
been subject to the
intentional or accidental
release of a hazardous
substance in sufficient
quantity that it could be a
risk to human health or the
environment
Depending on the nature of
the hazardous substance
may be localised to the spill
location. Records of clean
up may be available.
574
Hamilton
Gardens
Gun clubs or rifle ranges,
including clay targets clubs
that use lead munitions
outdoors, Landfill Site and
any other land that has
been subject to the
intentional or accidental
release of a hazardous
substance in sufficient
quantity that it could be a
risk to human health or the
environment.
Greatest risk is release of
landfill contents and any
leachate given site proximity
to the Wiakato River.
C2, G3,I
HAIL ACTIVITY
Comment
Greatest risk is at storage
and mixing/preparation
areas of pesticides.
Note: these properties are directly affected by the proposed roading
network and have a higher risk of encountering the area(s) where the
potentially contaminative activity may have occurred.
19
The site ID number is that allocated by Waikato RC.
100059484/3424455
ANNEXURE B - FIGURE 6: LOCATION OF POTENTIALLY CONTAMINATED PROPERTIES
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